Karimtharuvi Tea Estate Ltd. v. State of Kerala

60 ITR 262Supreme Court of India1966#750 most cited

What is Karimtharuvi Tea Estate Ltd. v. State of Kerala authority for?

The law applicable for an assessment year is the law as it stands amended on the first day of April of that financial year. Any amendments coming into force after April 1st do not apply to the assessments for that year.

136

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2010 to 2026.

Also referred to as

Karimtharuvi Tea Estate Ltd. v. State of Kerala · 60 ITR 262 SC · applicability of law · assessment year · law in force · amendment effective date · Income-tax Act 1961 · Section 143 · Section 142

Sections most often in play

Section 143(3)Section 143(2)Section 142(1)Section 115BBESection 1894Section 10(37)Section 143(1)Section 1961

Issues it is cited on

section 2(viii)section 56(viii)section 45(5)(c)section 155(16)section 23(1a)section 104section 45(5)(b)section 145b(1)section 194lakeyman insurancesection 160section 23(2)

Judgments citing Karimtharuvi Tea Estate Ltd. v. State of Kerala

Pawan Kumar, Fatehabad vs. Income Tax Officer Ward-1, Fatehabad

ITA 1112/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

…Court in CIT v. Scindia Steam Navigation Co. Ltd. (1961) 42 ITR 589 (SC) held that taxability must be determined by the law existing for the assessment year in question. This principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala (1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment year governs the assessment unless specifically provided otherwise. 54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that taxing provisions imposing a new liability are presumed to be prospective unless the statute clearly indicates otherwise. Likewise, in CIT v. Hind…

Sh. Tej Ram, Chandigarh vs. ITO, Ward -5, Panchkula

ITA 697/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19
For Respondent: Shri Suraj Bhan Nain, Advocate

…Court in CIT v. Scindia Steam Navigation Co. Ltd. (1961) 42 ITR 589 (SC) held that taxability must be determined by the law existing for the assessment year in question. This principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala (1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment year governs the assessment unless specifically provided otherwise. 54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that taxing provisions imposing a new liability are presumed to be prospective unless the statute clearly indicates otherwise. Likewise, in CIT v. Hind…

Raghbir Singh HUF, Chandigarh vs. ITO-Ward-1(3), Chandigarh

ITA 617/CHANDI/2023[2017-2018]Status: DisposedITAT Chandigarh11 Nov 2025AY 2017-2018
For Respondent: Shri Suraj Bhan Nain, Advocate

…Court in CIT v. Scindia Steam Navigation Co. Ltd. (1961) 42 ITR 589 (SC) held that taxability must be determined by the law existing for the assessment year in question. This principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala (1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment year governs the assessment unless specifically provided otherwise. 54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that taxing provisions imposing a new liability are presumed to be prospective unless the statute clearly indicates otherwise. Likewise, in CIT v. Hind…

Income Tax Officer, Ward-5(5), Chandigarh vs. Avtar Singh, Village- Kaimbwala

ITA 615/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19

…Court in CIT v. Scindia Steam Navigation Co. Ltd. (1961) 42 ITR 589 (SC) held that taxability must be determined by the law existing for the assessment year in question. This principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala (1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment year governs the assessment unless specifically provided otherwise. 54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that taxing provisions imposing a new liability are presumed to be prospective unless the statute clearly indicates otherwise. Likewise, in CIT v. Hind…

Sh. Amardeep Singh Athwal, Yamunanagar vs. ITO, Ward-1, Yamunanagar

ITA 566/CHANDI/2023[2015-16]Status: DisposedITAT Chandigarh11 Nov 2025AY 2015-16

Bench: BEFORE: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

…Court in CIT v. Scindia Steam Navigation Co. Ltd. (1961) 42 ITR 589 (SC) held that taxability must be determined by the law existing for the assessment year in question. This principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala (1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment year governs the assessment unless specifically provided otherwise. 54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that taxing provisions imposing a new liability are presumed to be prospective unless the statute clearly indicates otherwise. Likewise, in CIT v. Hind…

Sh. Amardeep Singh Athwal, Yamunanagar vs. ITO, Ward-1, Yamunanagar

ITA 565/CHANDI/2023[2014-15]Status: DisposedITAT Chandigarh11 Nov 2025AY 2014-15

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

…Court in CIT v. Scindia Steam Navigation Co. Ltd. (1961) 42 ITR 589 (SC) held that taxability must be determined by the law existing for the assessment year in question. This principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala (1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment year governs the assessment unless specifically provided otherwise. 54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that taxing provisions imposing a new liability are presumed to be prospective unless the statute clearly indicates otherwise. Likewise, in CIT v. Hind…

Sh. Ajit Singh, Pinjore vs. ITO, Ward-1, Panchkula

ITA 539/CHANDI/2023[2015-16]Status: DisposedITAT Chandigarh11 Nov 2025AY 2015-16
For Respondent: Shri Suraj Bhan Nain, Advocate

…Court in CIT v. Scindia Steam Navigation Co. Ltd. (1961) 42 ITR 589 (SC) held that taxability must be determined by the law existing for the assessment year in question. This principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala (1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment year governs the assessment unless specifically provided otherwise. 54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that taxing provisions imposing a new liability are presumed to be prospective unless the statute clearly indicates otherwise. Likewise, in CIT v. Hind…

Ranjeet Singh Khubber, Ambala vs. ITO, Ward 2, Ambala

ITA 50/CHANDI/2023[2012-13]Status: DisposedITAT Chandigarh11 Nov 2025AY 2012-13

…Court in CIT v. Scindia Steam Navigation Co. Ltd. (1961) 42 ITR 589 (SC) held that taxability must be determined by the law existing for the assessment year in question. This principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala (1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment year governs the assessment unless specifically provided otherwise. 54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that taxing provisions imposing a new liability are presumed to be prospective unless the statute clearly indicates otherwise. Likewise, in CIT v. Hind…

Sh. Pardeep Kumar, Ambala vs. ITO, Ward-3, Ambala

ITA 275/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19
For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

…Court in CIT v. Scindia Steam Navigation Co. Ltd. (1961) 42 ITR 589 (SC) held that taxability must be determined by the law existing for the assessment year in question. This principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala (1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment year governs the assessment unless specifically provided otherwise. 54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that taxing provisions imposing a new liability are presumed to be prospective unless the statute clearly indicates otherwise. Likewise, in CIT v. Hind…

Sh. Pargat Singh, Panipat vs. ITO, Ward -1, Kaithal

ITA 180/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19
For Appellant: Shri Navdeep Monga, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

…Court in CIT v. Scindia Steam Navigation Co. Ltd. (1961) 42 ITR 589 (SC) held that taxability must be determined by the law existing for the assessment year in question. This principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala (1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment year governs the assessment unless specifically provided otherwise. 54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that taxing provisions imposing a new liability are presumed to be prospective unless the statute clearly indicates otherwise. Likewise, in CIT v. Hind…

Sh. Gurinder Singh Grewal L/H of Parneet Kaur Grewal, Chandigarh vs. ACIT, Circle 4(1), Chandigarh

ITA 129/CHANDI/2023[2017-18]Status: DisposedITAT Chandigarh11 Nov 2025AY 2017-18
For Respondent: Shri Suraj Bhan Nain, Advocate

…Court in CIT v. Scindia Steam Navigation Co. Ltd. (1961) 42 ITR 589 (SC) held that taxability must be determined by the law existing for the assessment year in question. This principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala (1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment year governs the assessment unless specifically provided otherwise. 54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that taxing provisions imposing a new liability are presumed to be prospective unless the statute clearly indicates otherwise. Likewise, in CIT v. Hind…

M/S Yograj Chaudhary, Yamuna Nagar vs. ITO, Ward-5, Yamuna Nagar

ITA 116/CHANDI/2023[2017-18]Status: DisposedITAT Chandigarh11 Nov 2025AY 2017-18

…Court in CIT v. Scindia Steam Navigation Co. Ltd. (1961) 42 ITR 589 (SC) held that taxability must be determined by the law existing for the assessment year in question. This principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala (1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment year governs the assessment unless specifically provided otherwise. 54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that taxing provisions imposing a new liability are presumed to be prospective unless the statute clearly indicates otherwise. Likewise, in CIT v. Hind…

Sh. Ramesh Chand, Jagadhri vs. ITO, Ward-3, Yamuna Nagar

ITA 731/CHANDI/2022[2015-16]Status: DisposedITAT Chandigarh11 Nov 2025AY 2015-16
For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

…n CIT v. Scindia Steam Navigation Co. Ltd. (1961) 42 ITR 589 (SC) held that taxability must be Page 52 determined by the law existing for the assessment year in question. This principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala (1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment year governs the assessment unless specifically provided otherwise. 54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that taxing provisions imposing a new liability are presumed to be prospective unless the statute clearly indicates otherwise. Likewise, in CIT v. Hind…

Saroj Chaudhary Bala, Panchkula vs. ITO, Ward-4, Panchkula

ITA 635/CHANDI/2022[2017-18]Status: DisposedITAT Chandigarh11 Nov 2025AY 2017-18

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

…Court in CIT v. Scindia Steam Navigation Co. Ltd. (1961) 42 ITR 589 (SC) held that taxability must be determined by the law existing for the assessment year in question. This principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala (1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment year governs the assessment unless specifically provided otherwise. 54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that taxing provisions imposing a new liability are presumed to be prospective unless the statute clearly indicates otherwise. Likewise, in CIT v. Hind…

Smt. Shankri Devi, Panchkula vs. ACIT, Panckula Circle, Panchkula

ITA 596/CHANDI/2022[2013-14]Status: DisposedITAT Chandigarh11 Nov 2025AY 2013-14

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

…Court in CIT v. Scindia Steam Navigation Co. Ltd. (1961) 42 ITR 589 (SC) held that taxability must be determined by the law existing for the assessment year in question. This principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala (1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment year governs the assessment unless specifically provided otherwise. 54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that taxing provisions imposing a new liability are presumed to be prospective unless the statute clearly indicates otherwise. Likewise, in CIT v. Hind…

Harmala, Chandigarh vs. ITO, Ward 1(1), Nangal

ITA 432/CHANDI/2022[2015-16]Status: DisposedITAT Chandigarh11 Nov 2025AY 2015-16

…Court in CIT v. Scindia Steam Navigation Co. Ltd. (1961) 42 ITR 589 (SC) held that taxability must be determined by the law existing for the assessment year in question. This principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala (1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment year governs the assessment unless specifically provided otherwise. 54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that taxing provisions imposing a new liability are presumed to be prospective unless the statute clearly indicates otherwise. Likewise, in CIT v. Hind…

Amrinder Singh Khubber, Ambala vs. ITO, W-5, Ambala

ITA 1043/CHANDI/2019[2012-13]Status: DisposedITAT Chandigarh11 Nov 2025AY 2012-13

…Court in CIT v. Scindia Steam Navigation Co. Ltd. (1961) 42 ITR 589 (SC) held that taxability must be determined by the law existing for the assessment year in question. This principle was reiterated in Karimtharuvi Tea Estates Ltd. v. State of Kerala (1966) 60 ITR 262 (SC), holding that the law on the first day of the assessment year governs the assessment unless specifically provided otherwise. 54. In Govind Das v. ITO (1976) 103 ITR 123 (SC), it was emphasised that taxing provisions imposing a new liability are presumed to be prospective unless the statute clearly indicates otherwise. Likewise, in CIT v. Hind…

DCIT, Circle 4(2), New Delhi vs. Ms Communique Marketing Solutions Pvt Ltd, New Delhi

In the result, the appeal of Revenue is dismissed and cross-objection of Assessee is allowed

ITA 4762/DEL/2024[2017-18]Status: DisposedITAT Delhi07 Nov 2025AY 2017-18

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2017-18 Deputy Commissioner Of Income Vs. Ms Commmunique Marketing Tax, Circle 4(2), Solutions (P) Ltd., 5407, Arya Samaj New Delhi. Road, Karol Bagh, New Delhi-110005 Pan :Aaccc3432F (Appellant) (Respondent)

Section 115Section 115BSection 142(1)Section 143(1)Section 143(2)Section 250Section 37Section 68

…o Notification dated 15.12.2016 by which higher rate of tax was made applicable by represented cash credits under Section 68 of the Act. Ratio of judgment decided by the Hon’ble Apex Court in the case of Kasimtharuvi Tea Estate Ltd. Vs. State of Kerala (1966) 60 ITR 262 (S.C). Therefore, the Cross-objection nos. 1 to 3 are accepted. 11. In the result, the appeal of Revenue is dismissed and cross-objection of Assessee is allowed. Order pronounced in the open court on 07th November, 2025. (S RIFAUR RAHMAN) JUDICIAL MEMBER Dated: 07 November, 2025. Mohan Lal ITA No. 4762/Del.2024 & CO No.27/Del/2025…

Muktikanta Swain, Bhadrak vs. Income Tax Officer, Bhadrak

In the result the appeal of the assessee is partly allowed

ITA 147/CTK/2025[2017-18]Status: DisposedITAT Cuttack25 Sept 2025AY 2017-18

Bench: SHRI GEORGE MATHAN (Judicial Member), SHRI RAJESH KUMAR (Accountant Member)

For Appellant: Shri S.K.Sarangi, ARFor Respondent: Shri Vijay Singh, Sr. DR
Section 115B

…pply to the assessment for that year, even if the assessment is actually made after the amendments come into force. In this context, we rely on the judgment of the Hon’ble Apex Court in the case of Karimtharuvi Tea Estate Ltd., vs. State of Kerala reported in 60 ITR 262 (SC). 11. The Hon’ble Madras High Court in the case of S.M.I.L.E Microfinance Ltd., supra had categorically held that higher rate of tax at 60% u/s.115BBE of the Act will apply only to transactions from 01.04.2017 onwards and not prior to the said cutoff date. It was further held by the Hon’ble Jurisdictional High Court that for the prior transact…

Hamida Munir Chagani, Mumbai vs. ITO 24(2)(1), Mumbai

In the result, appeal of the assessee is allowed as per our aforesaid observations

ITA 4418/MUM/2025[2020-21]Status: DisposedITAT Mumbai22 Aug 2025AY 2020-21

Bench: Shri Amit Shukla & Shri Arun Khodpiaआयकर अपील सं. / Ita No.4418/Mum/2025 "नधा"रण वष" / Assessment Year :2020-21 Hamida Munir Chagani C-501, Green Park, Opp. New Link Road, Andheri (W), Mumbai-400 053 Pan :Aiapc7973L ........अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-24(2)(1), Mumbai ……""यथ" / Respondent

For Appellant: Shri Vimal PunmiyaFor Respondent: Shri Himanshu Joshi, Sr. DR
Section 143(3)Section 50CSection 50C(1)

…ding the 5% tolerance limit applicable for A.Y.2020-21.The appellant's claim that the 10% tolerance limit (effective from 01-04-2021) is retrospective is not acceptable. The Hon’ble Supreme Court in the case of Karimtharuvi Tea Estate Ltd. v. State of Kerala (60 ITR 262 (SC)] held that the Act, as amended on the first day of April of a financial year, applies to that year's assessments. Amendments effective after that date do not apply.The appellant's reliance on Maria Fernandes Cheryl v. ITO Is distinguishable, as the Tribunal's view on retrospectively lacks binding precedent, and the Finance Act, 2020, explicit…